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Why do the BBC and Ofcom not understand local radio?

Writer: David Lloyd
David Lloyd
11 hours ago
19 min read


BBC local radio prepares to reduce its service yet again.


Yet more programmes are to be shared - including local breakfast shows on Sundays reduced from fourteen to just six across England.


It's actually getting a little pointless pretending it's local at all now isn't it? We can see where this is heading.


Ofcom had said sharing was OK if in “the same recognized geographic area, regional culture, or identity” – and the BBC said just last year its programme sharing would be in areas “broadly akin to our English TV regions”. There are 12 TV regions, not 6.


The BBC will continue spending huge amounts on serving ever fewer people with its local stations as it runs them down. It will honour its duties under to its Charter “to reflect, represent and serve the diverse communities of all of the United Kingdom’s nations and regions” ever more poorly. It will use its huge, expensive local FM and DAB transmitter network to broadcast the same thing repeatedly. What’s the point?


It has happened not because of any lack of money but because the whole BBC local radio project has been mismanaged – and poorly regulated. 


Listeners know that. Those in the broadcasting business outside the BBC know that. And many I know in the BBC know that and get in touch with me; head in their hands at what the BBC is up to. The BBC has never been a wholly enthusiastic custodian of local radio – but thankfully there have been gifted champions on the ground there doing breathtakingly good work for which suits have taken credit – before then trampling on their staff.


Since Ofcom allowed BBC local radio to ditch its target audience and then to share programmes almost at will, audiences have walked away. Since pre-Covid, total listening has declined by about a third. 82% of BBC local radio listening is from those aged over 50 – and whilst the population aged over 50 has grown by 6% in this time, BBC local radio has shed 1.2m over 50s. There have been commensurate losses in demographics where Ofcom had expressed concern about the BBC’s performance.


In an independent survey I commissioned (Opinium. Fieldwork, England February 2026, sample 2000 aged 45+), over a third of BBC local radio weekly listeners aged 45+ believe ‘the BBC has ruined its local radio stations’.


This account summarises the failures of the BBC in local radio which, I believe, include a breach of a principal undertaking in its Operating Licence.  It also highlights regulatory failures by Ofcom which include: a failure to draw up the original Operating Licence in line with the relevant statutory Instrument; defective regulatory provisions within the Licence; and a year-long delay in deciding whether even to investigate an alleged breach.  


To amplify the latter, I believe BBC local radio did not deliver the required amount of ‘locally-made’ programmes last year. I complained at the time, yet Ofcom are still deciding whether to investigate – almost a year on. How can we have confidence Ofcom is holding publicly-funded broadcasting to account?


There are those who might just consider me just old fashioned, clinging onto a radio from long ago.  I’d counter I play with all manner of today’s tech in my day job and I’m hugely excited about the audio future. However, BBC local radio attracts an older demographic which is growing and radio is hugely valued by that demographic. I know that better than most.


There’s a local democracy deficit – and the Government urges us to rush out and make sure we have an FM radio for times of crisis. But what exactly is going to be on those radio sets? Local areas are uniquely and particularly affected by weather and strife – and nothing is as comforting as the human voice. And no-one is as worried as an old person alone. Yes, the BBC might get a local station on air eventually in extremis for few hours but it’s pot-luck whether you can find just the right broadcaster who can do that job well and know the patch and its people. Some community stations are doing a good job – but what’s happening to all the millions of pounds we are required by law to give the BBC?


BBC – you turned left with ‘local radio’ choosing yesterday’s technology and thinking rather than turn right. It was a critical error. And Ofcom – you didn’t quite understand it - and you let them.


Below, I have documented my concerns about BBC local radio and its regulation which underpin the assertions above. All points below relating to Ofcom have been put to the regulator. They are here for reference as I know others are making their views known in different ways.


This chapter must not be forgotten as it reflects so poorly on the BBC - an organisation richly resourced with public money to deliver a hugely distinctive tier of broadcasting. It has failed and has yet to concede those failures and act to remedy with an appropriate plan for local media fitting for the years to come, drawing on the latest thinking.


Ofcom tells me a ‘process’ is underway regarding concerns about BBC local radio’s performance prior to ‘a public update’ although it has not said what it is. Although I feel this falls rather short of the transparency required of a regulator and seemingly not part of a published process, my hope is that it will result in Ofcom declaring it is to implement corrective measures.


There seems a trend for bloggers to invent new words. May I volunteer BiBifiCation - where those in large public sector organisations devise jolly new plans of prima facie merit with an exciting title - at just the right time to distract from the architects' current failures. And so to promotion and retirement.


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Background


OUTSTANDING OFCOM COMPLAINT ABOUT LOCALLY-MADE HOURS


SUMMARY


  • November 2025 - Ofcom publishes report saying BBC is delivering sufficient local content in the year 24/25 in line with Operating Licence.

  • November 2025 - Complaint lodged with BBC contradicting that.

  • March 2026 - BBC reject complaint – and complaint lodged with Ofcom.

  • Ofcom process on whether to investigate complaint indicates ‘15 days’.

  • No decision from Ofcom on whether to investigate after almost 8 months

  • Thus no decision on even whether to investigate after almost a year from original complaint raised with BBC.


In the 24/25 Annual Ofcom report on the BBC, published in November 2025, Ofcom stated that the BBC had fulfilled its quota of locally-made hours as required by the Operating Licence, but would entertain complaints to the contrary.


I duly submitted a complaint to the BBC in November 2025 as complaints about the BBC must be made to the BBC first. The complaint was not upheld by the BBC’s Executive Complaints Unit and thus complaint BBC CAS-8233074 was submitted to Ofcom on March 6th 2026.


Under Section 1.24 of Ofcom’s procedures, a complaint which has made its way through the BBC complaints process will be considered by Ofcom and either rejected or investigated after ‘initial assessment’. Ofcom indicates that it expects (1.27) to judge this matter ‘on its face’ within 15 days.


After almost eight months Ofcom has still not decided whether to investigate.


After the initial three months’ delay, the Ofcom Content team indicated that a decision on whether to investigate would be reached within a month and they would let me know if not. It did neither.


These months of verification and additional enquiries apparently being undertaken appear substantively different from the gateway assessment described in paragraph 1.22 of the applicable Ofcom procedures.


It becomes increasingly difficult to understand what meaningful distinction Ofcom is drawing between the work now being undertaken and the formal investigation which its procedures say follows the gateway assessment. Under the Communications Act 2003 (Part 1, 3.3), Ofcom must act in a transparent, accountable, proportionate, consistent and targeted way.


It may well be that the issue I have highlighted about the BBC has become part of a broader issue being investigated by Ofcom. This is entirely within Ofcom’s powers, but nevertheless Ofcom’s procedures require that it decide explicitly whether to investigate the particular matter I have lodged.


In the light of this lengthy delay, I followed the Ofcom internal complaints process via the Corporation Secretary who insisted – twice - that the process was being followed.


·         The BBC Executive Complaints Unit had told me all relevant data was kept meticulously and ready to hand over to Ofcom. If such data was not ready and is now being re-cast and calculated at source, as is suggested to me by contacts at the BBC, that would surely amount to a BBC failure to report promptly. Such failure to declare an ongoing investigation and affording the opportunity to re-submit compliance data would raise a question as to whether the BBC is being afforded latitude that would not be available to other regulated broadcasters. Community broadcasters are sanctioned for late returns.


·         Ofcom had been alerted to the issue prior. In September 2025, before publication of the 24/25 Annual Ofcom report on the BBC, a complainant raising concerns was told by Ofcom: “We are currently in the process of our annual assessment of the BBC’s compliance for the reporting period of 2024/25 and we expect to publish our Annual Report and compliance assessment later this year. We will carefully consider the BBC’s compliance with its local radio obligations, taking into account the concerns you have raised.” It seems Ofcom failed to do this and (FOI 02174198) Ofcom later stated: “As the reported hours for each station met the relevant quota”...“The information provided by the BBC was considered sufficiently complete and reliable for the purposes of our assessment”. 


·         The figures had been published in November 2025 in the Ofcom Annual Report 24/25 on the BBC - and judged as compliant. Such has been the delay, that the Ofcom Annual Report 25/26 on the BBC is about to be published with a similar performance analysis against a revised Operating Licence. Yet there will have been no time for a formal investigation.

 

THE IMPACT OF CHANGE AT BBC LOCAL RADIO


SUMMARY


  • Changes began at BBC local radio as Ofcom took over from BBC Trust.

  • New Licence allowed more freedoms – contrary to explicit intention of statute.

  • Target audience changed and freedoms in shared programming consolidated.

  • Huge programme changes. Changes in approach, targeting and staffing.

  • Significant audience losses and falls in audience satisfaction.

  • BBC claims it is investing less in radio and more in other BBC services - yet BBC use generally also falls in regions.


In the last four years alone, audiences to BBC local radio have declined by almost a million listeners – a fall of 17%.


Social class DE audiences to local radio, about which Ofcom had expressed specific concern (Nov 23) about the BBC overall, have declined by around the same proportion.

The BBC began to make changes to its programming target (enabled by Ofcom under the First Operating Licence) and approach before Covid. In those last six years, total listening has declined by about a third. 82% of BBC local radio listening is from those aged over 50 – and whilst the population aged over 50 has grown by 6% in this time, BBC local radio has shed 1.2m over 50s.


The measures the BBC have introduced have been enabled by Ofcom. Poor judgement by the BBC in programme strategy means the stations have made themselves more vulnerable to the new commercial radio arrivals and thus the BBC is now delivering less public value to fewer people.


The BBC makes the case that its job is not just to serve local radio listeners but to serve all licence fee payers, choosing to shift budget from local radio to online. Yet the data below indicates that there has been an overall decrease in the total proportion of those sampling all BBC content in recent years


(Source, BBC annual reports, note different research source 22/23)


The BBC also makes the case that its budget is tight; and Ofcom appears to accept that in all its consultations on Licence changes. Whilst Ofcom should be aware of economic constraints and opportunities for all broadcasters, it should also be aware that many operators outside the BBC (and many hard at work within the BBC) see existing – and even reduced – BBC budgets for local radio as ample for delivering much more ambitious local radio


In an independent survey I commissioned (Opinium. Fieldwork, England February 2026, sample 2000 aged 45+), over a third of BBC local radio weekly listeners aged 45+ believe ‘the BBC has ruined its local radio stations’. 16% strongly agree that is the case. That research indicates almost half of BBC local radio listeners aged 45+ in England (47%) say the stations are not as local as they were with 19% strongly agreeing. despite the BBC being charged with providing distinctive programmes, almost half of weekly listeners aged 45+ (47%) say they are not as distinctive as they were. 

 

THE FIRST BBC OPERATING LICENCE FROM OFCOM


SUMMARY


  • Ofcom assumed oversight of the BBC from the BBC Trust in 2017.

  • Statutory instruction that the first Ofcom Operating Licence should not remove any requirement the Trust had.

  • Statutory instruction that the first Ofcom Operating Licence should safeguard where the BBC was delivering more than the Trust required – which the BBC was.

  • Statutory instruction that Ofcom should consider what else could be added to the Licence to create more distinctive services.

  • Ofcom failed to safeguard the significant extra local broadcasting hours already being delivered.

  • Ofcom took away target audience requirement.

  • Ofcom has conceded (FOI) it conducted no monitoring and asked no questions to establish what local radio was doing at the time.



At the time responsibility for BBC regulation passed to Ofcom, BBC local radio – in general terms - was broadcasting locally from 0600-1900 weekdays and extensively off peak and at weekend.


At that handover (Agreement between DCMS/Ofcom, 2016) Ofcom was required to “increase the current requirements on the BBC as a whole to secure the provision of more distinctive output and services. In particular, Ofcom must- (a) have a presumption against removing any of the current requirements which would result in the provision of less distinctive output and services; (b) (c) (d) consider the case for increasing the current requirements in areas where the BBC has exceeded those requirements or where this would support the provision of distinctive output and services”


The wording was explicit, not just to safeguard what the Trust required, but to keep what the stations were actually doing – even if that was more than was required.

Ofcom was also required to make decisions cognisant of the BBC’s Charter duty “to reflect, represent and serve the diverse communities of all of the United Kingdom’s nations and regions”; and the one relating to “all audiences” and “distinctive output” is self-evidently pertinent in matters relating to local radio’s local role to older audiences.

Safeguarding the character of a service is a challenge for any regulator. In this case, the blunt instruments generally used are target audience, news bulletins and the amount of locally-made hours. Ofcom must have agreed with the relevance and importance of these measures given it chose to use them in its Licence.


Ofcom, however, has recently confirmed to me (FOI 02123877) that it failed to even assess the levels of locally-originated output at the time, let alone safeguard them. It chose simply to consolidate the hours the Trust had required, including some idiosyncrasies.


In terms of target audience, at the time Ofcom took over, BBC local radio was charged with serving adults aged over 50. Ofcom took away this requirement, meaning that no BBC radio service was specifically charged with serving older adults.

In answering my enquiries, Ofcom did trumpet that it took steps to safeguard news bulletins “strengthen(ed) requirements by setting an enforceable condition for the first time that will require BBC Local Radio to provide ‘news and information of particular relevance to the area and communities it serves at intervals throughout the day’. It did not, however, notice that the small print revealed it had been me who had led to this adjustment – having written in response to the Consultation to highlight that the news commitment draft was unfit for purpose.


Ofcom, therefore, failed in its statutory duty to safeguard the character of BBC local radio in the First Operating Licence.  It failed to consider the case for increasing the current (BBC Trust) requirements in areas where the BBC has exceeded those requirements or where this would support the provision of distinctive output and services”


The foundation of all further BBC local radio regulation was therefore flawed. Every consultation which followed, therefore, would have been founded on a different premise had the original Licence been fit for purpose.

 

FIRST LICENCE CHANGE – Modernising the Operating Licence – June 2022


SUMMARY


  • Licence changes regarding local buried in broader 108-page document

  • Failures to explain implication of change to local radio listeners

  • Lack of clarity and failure to promulgate consultation to those affected in breach of Ofcom consultation principles

  • Negligible public response


The First Operating Licence gave the BBC much freedom to adjust its programming, but the BBC sought more.


In ‘Modernising the Operating Licence’, the BBC sought a number of changes regarding many of its services. Such a request once the new regulatory regime had settled was entirely appropriate.  However, in burying local radio changes within such a broadly-titled document, those affected simply did not identify the impact of the changes and the possible impact of them.


The section on the BBC local radio changes occupied a small part of a 108-page document and the title gave little away about its huge relevance to local radio.

The consultation referred to “retain(ing) quotas” for original locally-made programming” and the adoption of annualised quotas, without explaining what the quotas were or the impact the proposals would have. It was unclear.


As can be seen from the progress of my complaint BBC CAS-8233074, the move to annualised quotas has made the regulation of BBC local radio almost impossible.

The consultation generated only 38 published responses, including ten individuals. Only three of those individuals referred to BBC Local Radio and none appears to have addressed the principal consequences of the proposed change.


Given local radio’s large audience – and the anger expressed after the changes were implemented - that level of response would appear to be clear evidence that the consultation itself must have been unclear and poorly promulgated, contrary to Ofcom’s Consultation Principles which require that consultations "aim to reach the largest possible number of people and organisations who may be interested" in the outcome of their decisions.

 

SECOND LICENCE CHANGE – Changes to the BBC’s Operating Licence - October 2025


SUMMARY


  • The thrust of this consultation was misleading – suggesting the BBC wanted to do more do more local programming when more people are listening.

  • The BBC actually wanted further concessions to do less local programming.

  • Ofcom suggested the BBC had offered daytime commitments it was able to impose in any case and were already being delivered.

  • Much was made of the BBC’s volunteering of extra programming which would not be a commitment – and was not delivered.

  • Lack of clarity and failure to promulgate consultation to those affected in breach of Ofcom consultation principles.

  • Negligible public response.


The tone of this consultation was misleading, headlined by the suggestion that the BBC “wants to do more local programming when more people are listening” and suggested the BBC would add additional local programming at the weekends.


This licence change sought was to have off-peak programmes counted as local even if shared. It volunteered, in return, to have daytime (just 6am-2pm) programmes -which were already dedicated local output - to be required to be so.


Given the 6am-2pm programmes were already local, the impact of the change would be that even less dedicated and distinctive local output would be required of a network of part-time radio stations which cost licence payers £109m in content alone.

Ofcom chose to repeat the BBC’s claim that there’d be “more local programming” in a consultation which promised less. The BBC did promise some limited extra programmes at the weekends in some regions – but did not commit to these in the Licence – and several have not materialised.


The BBC also sought permission for an All-England show on Sundays (which was already underway) – which is what it stated it was planning in 2022. Ofcom did not explain why the BBC was asking again for permission to do something it had already asked for permission to do – and had started - the answer being it was struggling to reach its hours quota, the subject of my complaint.


Having stated previously that “over the coming year we expect to pay close attention to nations and regions provision and local radio…Monitor the impact of the changes to local radio in the nations – if our research shows that audience needs are not being met, we will consider whether to impose additional Licence conditions…”, there was no mention of such close attention in this request for further liberalisation.


The consultation gave a clean bill of health to the earlier changes, without any objective audience analysis; content monitoring; objective analysis of the adverse response; or reference to such things as the BBC’s Exec Complaints Unit finding (18th December 2024) of ”systemic failure” in “not respond(ing) adequately to significant breaking news” – areas which had been highlighted as potential worries by Ofcom when it originally gave permission to changes.  The consultation attached much merit to the peculiar measure that complainants had not kept on complaining. 


The consultation made no observation on why the Corporation appeared to be struggling to deliver the annual quota of 4,954 hours – to which it had signed up just three years prior.


The legal opinion I sought viewed this consultation as being wholly unclear to those whose views were being sought. Again, it was poorly promulgated with a paltry response of just 18 responses including just 11 individuals.


If it takes a year for the BBC and Ofcom to arbitrate on a complaint about locally-made programmes, then it cannot follow that the area is sufficiently penetrable for a lay-person to understand in a consultation.


NEIGHBOURING AREAS – PROGRAMME SHARING


SUMMARY


  • Local stations may legitimately share some programmes with neighbouring areas.

  • Ofcom defined those must be in ‘same geographic areas’.

  • Ofcom clarified these may not need not be necessarily adjacent areas.

  • BBC reassured that “groupings of stations aim to work within recognised regional cultures and identities".

  • In some cases, areas now have no possible connection – yet appear to be acceptable to Ofcom.

  • Ofcom undertook to monitor programme sharing but has produced no such monitoring.


BBC local stations have always shared some programmes – and some programme sharing is entirely appropriate and can benefit listeners.


The drafting and definitions of programme sharing arrangements were unfit for purpose in the Trust Licence; and they were described by the BBC as ‘perverse’ in 2025. Ofcom could wisely have made them more sensible in 2017.


In the Modernising the BBC Operating Licence consultation, Ofcom stated that “we consider that any station which is in the same geographic area, but which does not necessarily share a geographic border, would constitute a neighbouring station. We do not consider that this requires a change to the Licence. However, we believe it is important to monitor the stations between which the BBC shares its programming, as well as the specific programming being shared. We intend to do this going forward to ensure that the BBC continues to provide important local content such as local news”


Ofcom said the BBC is "confident that shared programming will resonate with audiences in the same way that the regional 6:30pm TV news bulletins do (and the majority of shared radio programming will cover similar geographic areas). It has said that the groupings of stations aim to work within recognised regional cultures and identities."

Ofcom , however, expressed caution over the scale of the proposed regions. In February 2023, of shared evening programming, Ofcom said “We question how shared programming which will cover such large areas will still be relevant to audiences, and therefore ask the BBC to explain why it considers this to be appropriate” 


Since these earlier statements the BBC has shared much more programming. The BBC chooses and changes its areas at will; and after 7.00pm, it chooses that even larger areas than afternoons have ‘recognised regional cultures’. 


Ofcom undertook to monitor the areas where programming is shared and yet has produced no evidence of such monitoring.  


By the time of the Ofcom statement on the 2025 Consultation, Ofcom appears to have no recollection (3.22) of its earlier concern about the size of regions even though it still (in 2025) cross-referenced the original Modernising the Operating Licence document when referring to the matter.


In its October 2025 consultation submission, the BBC said: "We consider that when the shared programmes cover areas broadly akin to our English TV regions these can count as “original locally made programming shared with neighbouring stations”. 


In Ofcom’s annual reports on the BBC, given it has accepted the BBC’s figures of locally-made hours without verification (See complaint BBC CAS-8233074) – it is not clear whether the hours the BBC has been counting and submitting as shared but  still locally-made - are shared with areas which can legitimately be deemed ‘neighbouring’.


A current example is that the BBC now proposes six Sunday breakfast shows. Is the BBC now to count these as locally-made? I have asked.


Ofcom had previously deemed ‘neighbouring’ to be not necessarily adjacent  areas – provided ‘in the same geographic area’ and had been reassured by the BBC’s insistence that the groupings of stations aim to work within recognised regional cultures and identities." All shared programming, therefore, must surely fit this definition if it is to be deemed locally-made – and Ofcom must ensure it does when verifying the quotas.


OFCOM’S PLEDGES OF MONITORING AND RESEARCH


SUMMARY


  • Ofcom’s specific undertakings to research response to the changes have not materialised.

  • Ofcom’s undertakings to monitor have not materialised.

  • Ofcom’s undertakings to add conditions to the Licence in the event of failures have not materialised - there have instead been further concessions.


Throughout all the adjustments to the BBC Operating Licence Ofcom has agreed, Ofcom has given assurances that there will be supervision, research and monitoring. This has not materialised and has not been cited in subsequent consultations.


When Ofcom originally agreed to the BBC’s request to network more programming across regions, it undertook (Letter to BBC, Feb ‘23) to “closely monitor the content and impact of the new service (including research on audience views)”. 


Ofcom said it will: “Monitor the impact of the changes to local radio in the nations – if our research shows that audience needs are not being met, we will consider whether to impose additional Licence conditions”.

"In addition, we are considering whether, in light of responses to our consultations on the new Operating Licence and the BBC’s changes to local radio provision, our proposals for regulation of local radio remain appropriate.”


Ofcom did commission some research (Community Research July 2024) into local media provision. Whilst an interesting piece of work, it did not indicate that BBC local radio listeners in England were content with the changes, as the Consultation which followed suggested. The survey used a sample of 100 participants, of whom 79 were from England. Only 28 of the total UK sample were aged over 55 – thus probably around 22 individuals aged over 55 in England. BBC local radio has a 14% reach of those aged over 55 – which suggests that possibly only three BBC local radio listeners aged over 55 contributed to this ‘online forum’ – and for the focus groups, that number would be reduced by half.


Save for this broad research on local media provision, I can find little evidence with appropriate sample size/methodology specifically on: the satisfaction of BBC local radio listeners; content analysis; objective audience research analysis or insight; or monitoring of which networked programmes are coming from which cities.


I was amused when I published the research I'd commissioned at my own expense. A vigilant, decent person in their broader research team noticed it and got in touch - likely unaware of my position in all this - to ask if they might borrow the tables.

 

THE BBC DECISION-MAKERS


There is such a thing as accountability. The BBC has senior executives who are well-paid to do a job and they hold the purse-strings.


In this case, a plan was hatched for how the BBC would proceed, particularly in the English regions. I do not see success – either in radio or indeed elsewhere – and we know the architects of that plan.


I interviewed Rhodri Talfan Davies when he was responsible for BBC local radio as Director of Nations in May 2023. He is now Deputy Director General of the BBC. The conversation was tetchy. He insisted puzzlingly of BBC local radio: “I think we’re targeting an elderly audience” at a time when I know that wasn’t what the people on the ground were being told - or anyone turning on the radio could hear.


He told me that good presenters were those with: “a real knowledge of the area. Somebody with an incredible, a wonderful sense of who their audience is, who they're speaking to” - whilst it appeared to be exactly those being made to feel unwelcome, sidelined or dispensed with. He reassured me that “we're not going to 10 or 12 (programmes shared across England), it's still 20 separate shows”. The BBC is now planning just six shows on a Sunday morning.


He also suggested he and his colleagues might fall on their swords? “Of course, I'm accountable.”


The plan for BBC local radio, without doubt, has been unsuccessful and is providing less public service to fewer people. There are many joined up models for audio and online which could have been thriving by now in capable hands, afforded the BBC budgets or less.


 
 
 

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